C.1 Use of Phosphate Salts and / or Water in the Preparation of Meat Products

The Food and Drug Regulations (B.01.090, B.01.091 and B.01.092) permit the addition of phosphate salts and /or water in meat products. The permitted forms of phosphates are listed in the FDR: Division 16 Table XII. The maximum permitted level of use is 0.5% calculated as sodium phosphate dibasic added to the product. All other permitted forms of phosphates must be converted to sodium phosphate dibasic equivalent when doing compliance calculations at the input level. The operator shall verify as part of the HACCP system that recipe and method of production will result in product compliant with the permitted level of use.

The following chart is used to convert other permitted forms of phosphates to sodium phosphate dibasic when calculating the amount of phosphates in a meat product formulation. The synonyms of each form are provided:

The following chart is used to convert other permitted forms of phosphates to sodium phosphate dibasic when calculating the amount of phosphates in a meat product formulation.

Form and Common Synonym

Chemical formula

Molecular weight

Factor

Disodium phosphate -sodium phosphate dibasic

Na2HPO4

141.98

1.0

Monosodium phosphate -sodium phosphate monobasic

NaH2PO4

119.98

1.18

Potassium phosphate, dibasic - dipotassium phosphate

K2HPO4

174.18

0.82

Potassium phosphate, monobasic -potassium biphosphate

KH2PO4

136.09

1.04

Potassium pyrophosphate, tetrabasic -potassium pyrophosphate

K4P2O7

330.34

0.86

Sodium acid pyrophosphate -disodium dihydrogen pyrophosphate

Na2H2P2O7

221.97

1.28

Sodium hexametaphosphate -sodium polymetaphosphate

(NaPO3)6

611.17

1.39

Sodium tripolyphosphate -sodium triphosphate

Na5P3O10

367.85

1.16

Tetrasodium pyrophosphate -sodium pyrophosphate, tetrabasic

Na4P2O7

265.94

1.07

Calculation of phosphate salts input levels

Example: Calculation of phosphate salt input levels in a product that is pumped or immersed in brine containing phosphate salts.

C.2 Curing of Prepared Meat Products

1.0 Curing by Standard Method

"Cured" (MIR) means, in respect of an edible meat product, that salt together with at least 100 ppm of sodium nitrite, potassium nitrite, sodium nitrate or potassium nitrate, or any combination thereof, was added to the meat product during its preparation.

The use of these nitrite or nitrates together with salt is therefore required when "cured" is listed as a mandatory process in Schedule 1 of the MIR. The nitrite and nitrate salts may also be used as preservatives where permitted in Schedule 1 of the MIR and in accordance with the Food and Drug Regulations Division 16, Table XI Part 1.

Meat products can be cured using a slow curing or a rapid curing method. The nitrate and/or nitrite salts are used in slow curing processes whereas the nitrites are used in rapid curing of meat products.

In the slow curing process the meat product is rubbed with a nitrate mixture, or soaked in a mixture of nitrate and water, for a period of several days or weeks. The nitrates are slowly converted by bacterial action to nitrite, which is the active curing agent. For example, dry cured hams are produced by coating hams with salt and nitrate.

The calculations for nitrate and /or nitrite in product(s) are made at the input level. For all curing methods (standard and alternative) the operator shall verify as part of the HACCP system that recipe and method of production will result in product compliant with the permitted level of use.

In products other than side bacon, the maximum input level of sodium nitrite salts is 20 g per 100 kg of meat product, i.e. 200 ppm. In the curing of side bacon, the maximum input level of sodium nitrite salts is 12 g per 100 kg of pork bellies, i.e. 120 ppm.

In the production of slow cured meat products, sodium nitrate salt at a maximum input level of 20 g per 100 kg of meat products, i.e. 200 ppm, may be used in addition to the nitrite salts. An exception to the maximum level of use is permitted for dry rub cured meat products on racks. The maximum level of use permitted is 62 g of sodium nitrite salts and 186 g of nitrate salts per 100 kg of meat product.

In the formulation of a cured meat product, the use of a previously cured meat product as ingredient in excess of 10% will necessitate recalculation of the nitrite/nitrate input to account for the contribution from those ingredients.

Registered establishments that store bulk nitrite or nitrate salts rather than Prague powder or similar premixes shall keep those salts under lock and key and account for their use to prevent an accidental misuse of those potentially dangerous compounds. The company shall maintain a log book for restricted ingredients such as nitrates/nitrites. The log should contain information such as: quantity on hand, quantity used, date, signature of employee. Inspection staff should review the log book periodically and initial it at the time of review. Binder units must have curing salts packaged separately in a coloured bag.

2.0 Curing by alternative method(s)

2.1 Preformed nitrites

Cultured celery powder (or other cultured vegetable juice powders approved for this purpose) may be used as an alternative source of nitrites in the production of cured or fermented meat products. Cultured celery powder contains preformed nitrites produced by bacterial action on nitrates present in the celery product. The level of preformed nitrites present in the celery powder must be declared by the manufacturer of the cultured celery powder. The producer of the meat product must determine the amount of cultured celery powder to be included in the formulation to achieve the minimum levels of nitrites (100 ppm, Meat Inspection Regulations, 1990) needed to cure the product without exceeding the maximum allowable limit (200 ppm, Food and Drug Regulations).

2.2 Non-converted nitrates

Non-converted celery juice powder (or other vegetable juice powders approved for this purpose) may be used as a source of nitrates in slow curing processes provided the product meets the nitrate/nitrite limits described under section 1.0.

Non converted celery juice powder (or other vegetable juice powders approved for this purpose) containing nitrates, together with a starter culture may also be used as an alternate method of curing meat products. Current regulations permit this method for unstandardized emulsified red meat products and standardized fermented emulsified red meat products, such as sausages. This method cannot be used to produce poultry products, or other cured meat products by pumping or injection procedures (e.g., brine injected ham). The operator must determine the amount of celery juice powder/vegetable juice to be included in the formulation to achieve the minimum levels of nitrate (100 ppm, Meat Inspection Regulations, 1990) needed to cure the product without exceeding the maximum allowable limit (200 ppm, Food and Drug Regulations).

The process must be validated to determine the minimum incubation period (hold time) when red meat products are formulated with nitrates and are subjected to heat treatment shortly afterwards. The operator's HACCP plan must provide the minimum incubation period required for conversion of nitrates into nitrites prior to the destruction of the starter culture by the heat treatment. If the culture manufacturer has not validated the incubation period for a particular heat treated product, the operator must provide validation results to demonstrate that the alternative curing method achieves the same results for that product(s) as the standard curing process described in section 1.0. Validation data must be reviewed and approved by the IIC and the Area Program Specialist. The validation should include:

defined nitrate concentration, culture type and incubation period;

two separate experiments, consisting of two batches each, of a meat product or a product representing a group of meat products. In one experiment, the batches are subject to the standard curing process as per section 1.0, while in the second experiment, the batches are subject to the alternate process;

for each of the batches within an experiment, residual nitrite levels must be assessed in triplicate from each batch at different time intervals i.e., at pre-incubation, post incubation, and immediately following thermal processing at day 7, 14, 30, 60, 125, 160, etc., and at the end of the shelf life of the product.

statistical analysis should confirm that the residual levels of nitrite in the alternate curing process are not lower than the residual levels present in the standard curing process during the shelf life of the product.

Other experimental approaches which satisfactorily demonstrate the safety of an alternative curing process may be submitted for consideration.

A process validation is not required when slow curing procedures are used because these slow processes will ensure adequate conversion of nitrates into nitrites.

The product label must conform to all current labelling requirements. For more information on labelling claims associated with meat products, please refer to the "Guide to Food Labelling and Advertising" published by the CFIA.